Before launch: replace [LEGAL ENTITY NAME], [STATE], [MAILING ADDRESS] and the effective date, and have this reviewed by an attorney familiar with insurance lead generation, TCPA and state privacy law. This is a starting draft, not legal advice.
Do not sell or share my personal information
Effective [DATE]
Why this page exists
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, businesses that "sell" or "share" personal information must tell you and must let you opt out. Other states, including Colorado, Connecticut, Virginia, Utah and Texas, give residents similar rights.
Toby is a referral service. When you complete our assessment we transmit your information to one or more licensed insurance agencies, and those agencies pay us a fee. Under California law that transfer is treated as a sale of personal information. We want to be straightforward about that rather than bury it.
What we sell or share, and to whom
- Identifiers — your name, phone number, email address and ZIP code.
- Commercial and demographic information — your age range, the coverage amount you selected, tobacco use and general health description.
- Internet activity — the advertising parameters attached to your visit, shared with advertising platforms for measurement.
These are disclosed to licensed insurance agencies and their authorised representatives so they can contact you about insurance, and to advertising and analytics providers. We do not knowingly sell or share the personal information of anyone under 16.
Your rights
- Know — request the categories and specific pieces of personal information we have collected about you, where we got it, why we collected it and who we disclosed it to.
- Delete — request that we delete personal information we collected from you, subject to legal exceptions.
- Correct — request that we fix inaccurate personal information.
- Opt out — direct us to stop selling or sharing your personal information.
- Limit — restrict our use of sensitive personal information, where applicable.
- Non-discrimination — we will not deny you service, charge you a different price or give you a lower quality of service for exercising any of these rights.
How to opt out or make a request
Email info@tobyinsurance.com with the subject line "Do Not Sell My Info" for an opt-out, or "Privacy Request" for access, deletion or correction. Include the first name, last name, phone number and email address you submitted, so we can find your record.
We will confirm receipt within 10 business days and respond within 45 days, extendable by a further 45 days where necessary. We may need to verify your identity before acting on a request. An authorised agent may submit a request on your behalf with written proof of authorisation.
Important limit on opting out
Opting out stops future sales or sharing. It cannot recall information already transmitted to an insurance agency. If an agency has your details and you want them to stop contacting you, you must also tell that agency directly, or reply STOP to their text messages.
Global Privacy Control
We honour the Global Privacy Control signal. If your browser sends one, we treat it as an opt-out request for that browser and device.
Contact
[LEGAL ENTITY NAME], [MAILING ADDRESS]. Email info@tobyinsurance.com.